Many members have asked our advice on a social media policy for their dental practice. The internet provides unique opportunities to participate in interactive discussions and share information on particular topics using a wide variety of social media, such as Facebook, Twitter, blogs and wikis. However, the team members’ use of social media can pose risks to confidential and proprietary information, and reputation, and could jeopardise compliance with legal obligations.
To minimise these risks, to avoid loss of productivity and to ensure that IT resources and communications systems are used only for appropriate business purposes, team members need to have a social media policy.
Practice owners have a duty of care to protect all members of the team, patients and clients from activities that might offend, disrupt, upset, discriminate, harass or bully an individual or group of individuals. All practice owners should establish a policy and procedures relating to social media and use of the Internet.
The GDC Standards for the Dental Team states (4.2.3):
You must not post any information or comments about patients on social networking or blogging sites. If you use professional social media to discuss anonymised cases for the purpose of discussing best practice you must be careful that the patient or patients cannot be identified.
There is further guidance on the GDC’s website
CODE has produced a Social Media Policy (M 233-SMD), which is free to members and an activity to review social media usage is automatically scheduled annually in iComply. This policy covers all individuals working in the practice at all levels and grades, including; partners, dentists, nurses, senior managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term employees, casual and agency staff (collectively referred to as team members in this policy).
Third parties who have access to our electronic communication systems and equipment are also required to comply with this policy.
This policy deals with the use of all forms of social media, including: Facebook, LinkedIn, Twitter, Wikipedia, YouTube, GDPUK, Instagram, Pinterest, all other social networking sites and all other internet postings including: blogs, photographs, videos and written information as well as ‘likes’ and other forms of commenting.
Your social media policy must contain a range of clauses to cover the uses and pitfalls of this form of communication. Here are a couple examples from CODE’s policy:
We recognise that employees may work long hours and occasionally may desire to use social media for personal activities at the office or by means of our computers, networks and other IT resources and communications systems. We authorise such occasional use so long as it does not involve unprofessional or inappropriate content and does not interfere with your employment responsibilities or productivity. While using social media at work, circulating chain letters or other spam is never permitted. Circulating or posting commercial, personal, religious or political solicitations, or promotion of outside organisations unrelated to the practice are also prohibited
The team are prohibited from using social media to:
- Breach our information and communications systems policy
- Breach our obligations with respect to the rules of relevant dental regulatory bodies
- Breach any obligations they may have relating to confidentiality;
- Breach our Disciplinary Rules
- Defame or disparage the practice or its affiliates, patients, customers, clients, business partners, suppliers, vendors or other stakeholders
- Harass or bully other team members in any way
- Unlawfully discriminate against other team members or third parties
- Breach our Data protection policy (for example, never disclose personal information about a colleague online)
- Breach the ‘Guidance on using social media’ from the GDC
- Breach any other laws or ethical standards (for example, never use social media in a false or misleading way, such as by claiming to be someone other than yourself or by making misleading statements)”
There are examples of disclaimers to be included in emails sent from practice premises and a warning that care should be taken when emails are forwarded – because this may disclose the addresses of earlier recipients (without their authorisation) to third parties.
The document covers the potential pitfalls of ‘blogging’ and gives guidance on the use of smartphones by practice staff. There is also advice about access to and use of the Internet and personal security settings. Finally, the CODE module establishes social media activity guidance for practitioners and general guidelines for using social media on behalf of the practice. The policy relating to social media usage should be read in conjunction with the harassment and bullying policy. Members can download the latest version of (M 233-SMD) from the iComply website.